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QUESTION

Your company is a security service contractor that consults with businesses in the U.S. that require assistance in compliance with HIPAA. You advertise a proven track record in providing information p

Your company is a security service contractor that consults with businesses in the U.S. that require assistance in compliance with HIPAA. You advertise a proven track record in providing information program security management, information security governance programs, risk management programs, and regulatory and compliance recommendations. You identify vulnerabilities, threats, and risks for clients with the end goal of securing and protecting applications and systems within their organization.

Your client is Health Coverage Associates, a health insurance exchange in California, and a healthcare covered entity. Because of the Patient Protection and Affordable Care Act (ACA), the exchange enables individuals and small businesses to purchase health insurance at federally subsidized rates. In the past 6 months, they have experienced:

  • A malware attack (i.e., SQL Injection) on a critical software application that processed and stored client Protected Health Information (PHI) that allowed access to PHI stored within the database
  • An internal mistake by an employee that allowed PHI to be emailed to the wrong recipient who was not authorized to have access to the PHI
  • An unauthorized access to client accounts through cracking of weak passwords via the company's website login

They would like you to develop a security management plan that would address the required safeguards to protect the confidentiality, integrity, and availability of sensitive data from the attacks listed above and protect their assets from the vulnerabilities that allowed the attacks to occur. 

Write a 1- to 2-page high-level executive summary of the legal and regulatory compliance requirements for the company executives. The summary should provide accurate information on the requirements under HIPAA for securing Protected Health Information (PHI), as well as FISMA and HIPAA requirements for a Security Plan and the scope of the work you will perform to meet the company's requests.

Compile a 1- to 2-page list of at least ten of the CIS Critical Security Controls that provide key alignment with the administrative (policies), physical (secured facilities), and technical safeguards required under HIPAA to protect against the attacks listed above. Include corresponding NIST controls mapped to the selected CIS Critical Security Controls.

Write a 1- to 2-page concise outline of the contents of the security management plan to include the policies they will need to manage, protect, and provide access to PHI, the recommended risk management framework the company should adopt, as well as key elements they should include in their Plan of Actions and Milestones.

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